It Seems So Simple ...

There shouldn’t be a constant barrage of differing interpretations of FAA policy and regulations


Level the playing field, standardization, equality, fairness … no matter how you describe it, the fact that we continually receive differing interpretations of regulations and policy from the FAA would lead us to believe that they have never heard of it. Not so. I have been working closely with the FAA for years and can remember multiple attempts at different levels within the FAA to attempt to “level the playing field.”

My first real FAA experience at the national level occurred a few years back, about 1996. There had been a recent effort to clarify tool calibration policy across the country. Flight Standards had issued an order to all safety inspectors reinforcing the need for tool calibration and explaining what qualified a specific tool or piece of test equipment as needing regular calibration. It seemed so simple.

Bob and his bucket
I had stopped in to see an old friend (we’ll call him Bob) who was working as the chief inspector at a repair station that I had worked with in the past. We were deep into hangar talk, sharing tales of customer experiences and FAA encounters, when Bob told me a story about his FAA safety inspector and his most recent visit to the repair station.

By this time I had met FAA safety inspectors from different district offices all over the country through my past positions and consulting assignments. I knew there were nearly as many different rule interpretations as there were inspectors. But I hadn’t yet seen an example of such complete nonsense as I was about to hear from Bob.

I told you that at this time there was a newfound focus on calibration of tools. When I was talking with Bob, I looked in the corner of his office and I saw a 5-gallon bucket. I thought it was being used for trash or something so I didn’t notice anything odd until he told me what exactly it was for.

He had just finished marking the bucket with pieces of duct tape precisely at the 1-, 2-, 3-, and 4-gallon marks. Bob pointed to the bucket as he began to tell me the story.

His particular FAA inspector was a man who I actually respected. He gained my respect through his knowledge of the regulations and the complexities that surround the many different areas of the regulations and how they relate. So at first I found it difficult to believe what Bob had told me. When the inspector had been by the last week to visit and walk through the repair station with Bob, he was on a mission to make sure that all required tools and testing equipment had been calibrated and that the repair station could demonstrate such. Quite a simple task.

The inspector had asked to see a few work orders and was spot checking for tasks that would require a special tool or some piece of test equipment. The first work order he opened had a task that involved performing a compressor wash on the aircraft engines. He asked Bob how the compressor wash had been performed. The corrective action of the work order stated that the compressor wash had been performed in accordance with the appropriate Pratt & Whitney PT6A maintenance manual. Bob pulled out the manual and turned to the procedures for a compressor wash. The procedure calls for compressor wash fluid to be run through the compressor at a specific flow rate, 3 to 5 gallons per minute.

The inspector asked Bob, “How do you know that you are running the fluid through the compressor at the correct rate?” This obviously caught Bob off guard, since compressor washes are such a common process.

The conversation went downhill and the inspector left after telling Bob that according to the new “national policy” he would have to calibrate the 5-gallon bucket and be able to demonstrate a flow rate as required by the maintenance manual. What I was looking at in the corner of Bob’s office wasn’t a nicely decorated trash can — it was a finely tuned piece of test equipment that was required to be recalibrated every 12 months (to the day). I laughed out loud. Bob didn’t think it was as humorous as I did.

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